Under the Rental Housing Integrity Improvement Project (RHIIP) initiative, HUD is responsible for ensuring that the proper subsidy is provided to household through its rental assistance programs. The amount of rental assistance paid on behalf of the household is calculated using their annual income, less allowable deductions. Therefore, it is critical that Owners and Management Agents (O/As) obtain and adequately verify annual income and benefit information in making rental housing subsidy determinations.
To that end, HUD developed a program, the Enterprise Income Verification (EIV) system. HUD considers the ElV system to be an integral component in the Rental Housing Integrity Improvement Project (RHIIP) initiative to reduce errors and improper payments in the administration of its assisted housing programs. HUD feels that full implementation of the EIV system will increase the accuracy of rent and income determinations, thereby better ensuring that the right benefits go to the right persons.
HUD now considers the highest verification method to be the upfront income verification (UIV). UIV is the verification of income, before or during a household recertification, through an independent source that systematically and uniformly maintains income information in a computerized form for a large number of individuals.
O/A’s are encouraged to incorporate the use of the EIV system in their day-to-day operations and Contract Administrators are encouraged to use the system in the performance of MORs, the purpose of which is to ensure the reduction in improper payments of HUD subsidies. And, the CAs will monitor the necessary policies and procedures required in the use of the EIV system.
To begin with, O/As are required to maintain, communicate, and enforce standard operating procedures related to securing EIV data. The purpose of such a document is to provide policy and procedures to everyone that has access to the EIV secure website system. This could include staff, consultants and contractors on the acceptable use, disposition and storage of data obtained through EIV (Enterprise Income Verification).
HUD states “EIV as a system is defined as an external data source that provides information either through computer matching, data storage, retrieval and transmitted either via computer, fax, or email”. Verification of income, assets and expenses received through the U.S. Mail will also be treated in the same format as EIV data.
The integrity and availability of data in EIV is essential. The data contained therein needs to be protected from unanticipated or unintentional use and disclosure. Through its system security measures, HUD restricts the use of this information to program administrators such as O/As, HUD approved officials such as contract administrators (CAs) under contract with HUD, and HUD's OIG, the law enforcement arm of HUD.
So much emphasis was put on “security”; that it was decided that it would be beneficial to have a designated person to be responsible for ensuring compliance with the EIV Security Policy. So, not only will the following items be included in the security policy but a “designated person” should be responsible for the Compliance of the policy and procedures.
Usage;
Rules of Behavior;
Certification and Recertification
Safeguards;
Reports;
Resolving Discrepancies; and
Consents including but not limited to the 9887 / 9887-A
The “designated person” will maintain a record of all users who have approved access to EIV data. This data record should be reviewed on a regular basis to determine if users still require access. And, should it be determined that the access of a user is no longer required then access should be terminated or modified based on the user’s responsibilities or duties.
EBMC’s Designated Person AKA EIV Coordinator, Program Administrator or Security Officer is:
Stephen Burger
6600 Hunter Drive, Rohnert Park CA 94928
707-584-5123 steveburger@ebmc.com
Attachments;
History______________________________________________________________
Gabrielle Harris composed this Policy/Procedure on 02/09/2011 01:41:21 PM.
Gabrielle Harris edited this Policy/Procedure on 02/09/2011 01:44:16 PM.